Analysis of ‘Bureaucratese’ in an FAA Response Letter

The FAA response letter consisted of six paragraphs. Each paragraph is presented below, as a JPEG image, followed by aiREFORM’s analysis, in the form of comments.

The one positive in this opening paragraph is the admission of the obvious: “…aircraft noise can be disruptive and result in a variety of effects.”As for the negatives of FAA’s opening paragraph:

The response cites FAA’s alleged ‘long history of studying noise related effects’, but glosses over the more significant reality: that FAA does nothing meaningful to mitigate noise impacts today.

The response claims that FAA has a long history of STUDYING “…in order to minimize them to the extent possible through research and development and mitigation measures.”This perpetual STUDYING is just an ongoing delay tactic, to accommodate the status quo. And, clearly, FAA is not pursuing the easiest available mitigation measure: all FAA needs to do is implement substantial hourly operations limits on hub airports (where airlines routinely exceed practical flow rate limits, creating repetitive noise impacts) and most noise impacts will disappear. And, this is a ‘two-fer’; such capacity management would also eliminate nearly all system delays that cascade from a small handful of hub airports.

And, if the ‘appreciation’ for the citizen sending the letter was true, the response would have gone much further. Instead of just blowing off the concerns with layers of bureaucratese, further questions would have been asked, to clearly define the concerns stated in the original letter.

First sentence: The opening line is just odd (and self-promoting, even delusional?); the citizen writing the original letter does not necessarily know what FAA purports to be their ‘primary mission’. In fact, the citizen’s letter showed clearly, the concern was more about the adverse environmental impacts of what appears to be FAA’s ‘primary mission’ of eliminating all obstructions to maximum commercial aviation activities (and thus airline profits). Frankly, a more thorough analysis of the facts would reveal that, in fact, FAA’s primary mission has become to perpetuate their own bloated bureaucracy, and to maximize the wealth being redistributed to FAA employees, including ample retirement pensions often supplemented with post-retirement income earned while ‘consulting’ for the businesses they refuse to regulate.

Second sentence: there is a tiny speck of light in this line. It declares, essentially, that FAA DOES HAVE AUTHORITY to manage where airplanes fly, so long as FAA either deems the flight unsafe or inconsistent with the Federal Aviation Regulations (FARs). So, here is a simple and ‘transformational’ solution (to use Bill Shuster’s and Nick Calio’s latest favorite word): Congress needs to direct FAA to draft FARs that protect people from aviation noise and other pollution. Long ago, Congress directed FAA to draft FARs that protect airplanes from each other. In the interim decades, Congress has repeatedly directed FAA to draft FARs that protect aviation from people, but with legislation such as ANCA, the legislation went too far. Now, the balance needs to be restored.

Third sentence: this is really just filler. It adds nothing meaningful to the response, but tries to build an air of system complexity. I.e., our job has so many factors, how do we manage to even remember to zip our flies? This is, of course, utter bullshit, perpetuated by the Av-Gov Complex.

The opening line is just a standard FAA manipulation of the facts. It has been clearly established, for example, that some communities that had near-zero noise issues in past decades have suddenly been impacted by streams of repetitive flights. Why? Because FAA is using NextGen to remove all of the noise mitigation procedures evolved over many decades, and FAA is replacing them with automated flight procedures that feature turns lower and closer to the airports. The airlines are keen on this as it may eventually enable them to reduce flight crews to just one pilot on board.

As for technological progress … yes, we have substantially improved efficiency and lowered noise levels from the first-generation jet engines of the 1960s. Those early jet engines were TERRIBLE, so vast improvements were to be expected; but, an agency hell-bent on accommodating airline profits plainly throws out these gains, when ATC ‘collaborates’ with the airlines to concoct new routes impacting new communities with repetitive noise. The added line regarding FAA’s “…advancing the maturation of technological improvements…,” … well, this is just more fluffy and deceptive bureaucratese. Note the closing sentences, too:

“To the extent that airlines can afford to purchase and operate newer aircraft…” implies FAA has no authority to ORDER such capital improvements to comply with environmentally necessary FARs. FAA has plenty of authority; any they may lack can be ordered by Congress, to serve everyone, not just industry.

“…more efficient ATC techniques allow aircraft to get on the ground and climb out of the airport terminal area more quickly…” only further confirms the point made above: that the REAL objectives of NextGen (which FAA, Shuster et al, and lobbyists like Airlines for America are careful to not talk about!) are to scrap noise mitigation procedures and eventually fully automate procedures so as to accommodate future single-pilot operations.

This paragraph paints a picture of complexity and inertia; e.g., that FAA has invested so much money and research into ‘studying’ the problems, changes are thus made very difficult. But, the paragraph also identifies the layers of delay tactics. FAA’s failure persists because, in fact, FAA’s studies and FAA’s decisions are erroneously based on the wrong noise parameters. The 65 dNL noise parameter is utter garbage, abandoned decades ago by most other nations.

Even if (and when) FAA gets around to producing better studies using more appropriate noise parameters, no improvements will likely happen. As a line in the paragraph states, “…these recommendations will eventually be submitted to the FAA for consideration….”The key word is ‘consideration’. Until Congress mends the FARs to adequately balance aviation impacts against the quality-of-life interests of the general public, FAA effectively has no obligation to do anything. And the FAA track record is very clear: we can rely on FAA serving the industry, with zero regard for impacts on the people.

Reading the closing line of this paragraph, one wonders: after dealing with FAA’s chronic institutional arrogance, who in their right mind would want to be added to any mailing list for ‘updates’? Really … how stupid do FAA officials like Lourdes Maurice (and the illegible name that signed for her!) think we citizens are?

FAA knows that the Roundtable Groups are a joke, a point clearly made in the letter to Secretary Foxx. These groups are stacked with pro-aviation members, and sized-up with far too many members, to the point of having no ability to focus on and resolve even the simplest issues. FAA enjoys the fact that, because a group has been created, they can trumpet to Congress that citizens are now involved. This ignores the fact that, in nearly all FAA-related citizen groups, the net result is to all but eliminate the ability of a single concerned citizen to effectuate change. Once a group is formed, our best citizens, those who care enough to speak up as noise activists, are forced to channel their concerns and suggestions through one more layer of bureaucracy. The groups are staffed by citizen volunteers (as well as FAA employees and aviation ‘stakeholders’) who commonly receive perks such as paid ‘vacations’ to attend noise conferences in places like Palm Springs.

Mid-paragraph, a sentence repeats another deep concern already noted in this analysis: that FAA is under no obligation to actually do anything if and when a group produces ‘ideas for mitigation’.

The closing sentence is effectively an admission that the agency is captured by industry and not serving the people. It presents a ‘divide and conquer’ strategy, pitting neighborhood against neighborhood’, while implying that FAA can do nothing to mitigate aviation noise impacts. Clearly, this is false. FAA may want to do nothing, but in reality, if either FAA took action ‘in the name of safety and efficiency’ to really MANAGEaviation noise impacts, or if Congress legislated and then followed through to compel FAA to do this, we could have the best: a few good, profitable airlines serving the people at our publicly funded airports, with almost none of the noise impacts.

The line, “…we are taking resident’s concerns seriously…”seems astoundingly insincere, as the problems persist after many decades. And, although the response letter says “…we appreciate your interest in the safe and efficient operation of the airspace system…,” in fact there was NOTHING in the letter expressing any interest in either safety or efficiency. Clearly, the interest in the citizen’s letter was to point out FAA’s ongoing and chronic failure to resolve environmental impacts near LGA and JFK, and to advocate for the removal of Michael Huerta, as well as his replacement with an individual who is “…responsive to citizen complaints….”

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